The other day I had yet another conversation with someone who was confused about the spill response training he needed for his operation. The first person he talked to said he needed 40 hours of training; the next person told him he needed 24 hours. Then he read about other training that requires eight hours or less. What does the U.S. Occupational Safety and Health Administration (OSHA) require and, more importantly, what is best for your operation?
An easy answer is: "Don't spill anything," but realistically, the potential for a spill or accidental release of chemicals always exists. Incident response might involve anything from a mop-and-bucket cleanup to an area evacuation with site controls, decontamination activities and fully encapsulating chemical-resistant suits with self-contained breathing apparatus. Training requirements could vary from just minutes to several days.
You must decide how you will handle a spill before it occurs. Time is a critical factor in any emergency ," decisions that could impact lives and the future of your plant need to be made quickly.
Many factors will dictate your level of response. Such factors include the properties of facility chemicals such as toxicity and vapor pressure, as well as the chemical quantities, types of processes and availability of local emergency resources. The potential impact on your employees, your operations and the community also are important factors.
Just because you handle chemicals or might need to respond to spills does not necessarily mean you must invest a lot in training and equipment. However, a significant investment may be warranted in some cases.
OSHA's Hazardous Waste Operations and Emergency Response Standard 29 Code of Federal Regulations (CFR) 1910.120, also know as the HAZWOPER standard, establishes safety and health requirements for "emergency response operations for release of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard."
The bulk of the HAZWOPER standard, Sections b through p, covers hazardous waste operations such as clean-up procedures at hazardous waste sites and operations involving hazardous waste at treatment, storage and disposal facilities. The final section of the standard, Section q, covers emergency response.
When researching HAZWOPER issues or signing up for training, it is important that you address the appropriate issue. It is not uncommon for people to enroll in a HAZWOPER class to learn about spill response only to find out later ," during the actual training ," that the class focuses on hazardous waste sites.
Note: OSHA regulations, definitions, interpretations and resources for emergency response are available at www.osha.gov/SLTC/emergencyresponse.
When it comes to chemicals, a variety of definitions for "hazardous" exist. The U.S. Department of Transportation (DOT) is concerned with the hazards of materials in transport and orients its definitions of hazardous toward air transportation and other specific transport concerns. The U.S. Environmental Protection Agency (EPA) is concerned with the impact on the environment when materials are released or disposed and makes hazardous determinations based on environmental and human health risks.
OSHA is concerned with the hazards of materials to which workers might be exposed in the workplace. Any chemical that might present a health or physical hazard is defined as a hazardous chemical under the OSHA Hazard Communication Standard. Health hazards include any adverse health effect from irritants to corrosives or carcinogens.
The HAZWOPER standard applies to releases of hazardous substances. Although it is an OSHA standard, it does not use the Hazard Communication Standard for hazardous chemicals. The HAZWOPER standard traces its origin to an EPA law, the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as Superfund), and derives its definition of hazardous substances from CERCLA regulations. The CERCLA definition is based on the substance's potential impact on the environment and the community.
In addition to hazardous substances listed under CERCLA, HAZWOPER also includes certain biological and disease-causing agents, DOT hazardous materials and hazardous waste in its definition. Biological and disease-causing agents include anthrax or other bioterrorism agents. Table 1 provides a summary of the classes of hazardous substances under HAZWOPER.
The definition might seem a bit confusing. The basic idea, however, is to include chemicals that would present a significant hazard to people or the environment if spilled or released. Chemicals that do not fall into one of these categories might still present a hazard to employees and emergency responders, but technically do not trigger HAZWOPER requirements.
Understanding emergency response
The emergency response will trigger many of the HAZWOPER requirements. The standard defines emergency response as:
", a response effort by employees from outside the immediate release area or by other designate responders (i.e., mutual aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses."